United States v. Mendez-Sanchez

OPINION

GOULD, Circuit Judge:

We consider the relationship between a motion to substitute counsel and an invocation of a defendant’s Faretta rights. We hold that while a defendant may invoke his or her self-representation rights after a denial of a motion to substitute counsel, the invocation must be unequivocal. A request to represent oneself made while at the same time stating a preference for representation by a different lawyer and rearguing the change of counsel motion is insufficient to invoke Faretta.

I

A federal grand jury returned an indictment against Defendant Roberto Mendez-Sanchez…